Article 2 (Liability for Tax Payment)

Individuals falling under any of the following subparagraphs shall be liable for paying income tax on their respective income under this Act. 1. Residents 2. Non-residents with domestic source income

An entity not a corporation, other than an entity deemed a corporation under Article 13 (4) of the 「National Tax Basic Act」 (hereinafter referred to as an "entity deemed a corporation"), shall be treated as one resident if it has a principal office or the principal place of management of its business in the Republic of Korea, and as one non-resident otherwise, and this Act shall apply accordingly. However, in cases falling under any of the following subparagraphs, the obligation to pay income tax or corporate tax (limited to cases where the respective member is a corporation under the 「Corporate Tax Act」 (including entities deemed corporations); hereinafter the same shall apply in this Article) on income shall be borne by each member of the entity, according to the classification of income under this Act or the 「Corporate Tax Act」. 1. Where the ratio of profit distribution among members is determined and the ratio of profit distribution for each member is confirmed. 2. Where the ratio of profit distribution among members is not determined, but it is confirmed that profits are actually distributed to each member.

Notwithstanding paragraphs ③ and ④, if an investment vehicle established overseas (meaning an organization that acquires, disposes of, or otherwise operates investment target assets with funds solicited from investors, and distributes the results to investors, thereby attributing income; hereinafter the same shall apply) that is an entity not a corporation, other than an entity deemed a corporation, is deemed the beneficial owner of domestic source income pursuant to Article 119-2 (1) 2., the overseas investment vehicle shall be liable for paying income tax as a non-resident.